20240917PAC to Bayer 79-86.pdf

RECEIVED
Tuesday, September 17, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 17, 2024
Thomas J. Budge
ti(&racineolson.com(C)
Brian C. Collins bcollins(&consultbai.com
Greg Meyer gmeyerkconsultbai.com
Kevin Higgins khiggins(c�r�,energystrat.com(C)
Neal Townsend ntownsendkenergystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 6 (79-86)
Please find enclosed Rocky Mountain Power's Responses to Bayer's 6th Set Data Requests 79-86
and Attachments. Provided via BOX are the Confidential Attachments. Confidential
information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the
Idaho Public Utilities Commission's Rules of Procedure No. 67—Information Exempt from
Public Review, and further subject to the non-disclosure agreement (NDA)executed in this
proceeding.
If you have any questions, please feel free to call me at(801) 220-2313.
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancenae isg insi hg t�(C)
Matthew Nykiel/ICL matthew.nykielkiamail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Ronald L. Williams/PIIC rwilliamsghawlevtroxell.com
Brandon Helgeson/PIIC bhelfzeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinskmwanalytics.com
Val Steiner/PIIC val.steiner(cr�,itafos.com
Kyle Williams/PIIC williamskkbvui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(),puc.idaho.gov
S ecretary(a),puc.idaho.gov

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 79
Bayer Data Request 79
Wildfire Mitigation Plan. Does the Company intend to seek deferred accounting
treatment for any of the costs included in the Wildfire Mitigation Plan filed June
7, 2024 in Case No. PAC-E-24-09? If yes, please identify the costs that the
Company would propose to defer.
Response to Bayer Data Request 79
PacifiCorp objects to this data request to the extent that it requests information
that is outside the scope of the proceeding. Subject to and without waiving the
foregoing objection, PacifiCorp responds as follows:
The Company has not requested a deferred accounting order in Case No. PAC-E-
24-09 for costs identified in the Wildfire Mitigation Plan (WMP).
Recordholder: Nick Highsmith
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 80
Bayer Data Request 80
Generation Overhaul Expense. Please refer to Attachment Bayer 49.
(a) What is the projected generation overhaul expense for Jim Bridger Unit 1 and
Jim Bridger Unit 2 for each year, 2024-2028?
(b) All things being equal, does RMP expect generation overhaul expenses for
Jim Bridger Unit 1 and Jim Bridger Unit 2 to be lower now that they operate
as gas units rather than as coal units? If not,please explain.
(c) Please provide the annual generation overhaul expense for the Naughton 3
unit in each of the six years prior to its conversion to natural gas.
Response to Bayer Data Request 80
(a) Please refer to Attachment Bayer 80-1.
(b) Overhaul expense for Jim Bridger Unit 1 and Jim Bridger Unit 2 post-
conversion to natural gas are expected to be lower compared to coal operation.
(c) Please refer to Attachment Bayer 80-2.
Recordholder: Aaron Lively
Sponsor: Brad Richards

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 81
Bayer Data Request 81
General. Is the Company aware of any errors contained in its rate case filing? If
yes, please provide a detailed description of each known error, explain how each
of the errors impacts Exhibit No. 48, and provide the adjustment in Excel format
that would be necessary to correct the error. Please update this response as any
additional errors become known to the Company.
Response to Bayer Data Request 81
Please refer to the Company's response to IPUC Data Request 242. In developing
the weather normalized load forecast, the data imported for the daily and holiday
variables in the weather spline models erroneously excluded the January 2021
through September 2021 period. Incorporating January 2021 through September
2021 daily and holiday variables would result in a de minimis 59 megawatt-hour
(MWh) at sales (or 63 MWh increase at input) in the weather adjustment. This
impact would increase the system energy (SE) allocation factor to Idaho by
0.0018 percent(63 MWh/3,567,408 MWh). An increase of a smaller magnitude
would be experienced on the system generation (SG) allocation factor. The
Company has not prepared an adjustment to update the full impact to revenue, net
power costs (NPC), and allocation factors that would be required for any change
in load. Additionally, the Company is not proposing to update the filing for the
aforementioned error.
The Company is not aware of any additional errors in the filing.
Recordholder: Nick Highsmith
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 82
Bayer Data Request 82
Major Plant Additions. Regarding Ms. Shelley E. McCoy's major plant
additions included in Exhibit No. 48, Adjustment 8.5.
(a) Please identify any major capital additions included in Adjustment 8.5 that
have now been cancelled or delayed past the end of the forecasted 2024 test
period.
(b) Please identify any major capital additions included in Adjustment 8.5 where
the in-service date has been delayed from the date assumed and shown in
Adjustment 8.5 (but still falls within the 2024 test period).
(c) Please identify any major capital additions included in Adjustment 8.5 where
RMP has updated the anticipated capital addition amount(but still falls within
the 2024 test period).
(d) Please prepare an updated version of Ms. McCoy's Adjustment 8.5 that
reflects the latest in-service date and capital additions amount as provided in
this response comparable to RMP's as-filed Adjustment 8.5 and derive the
adjustments by FERC account and allocation factor that would be necessary to
reflect the updated information in the RAM. Please provide this work paper in
Excel format with formulas intact.
(e) Please provide work papers deriving any other rate base or expense
adjustments (i.e. depreciation reserve, depreciation expense, ADIT, property
taxes, O&M expenses, etc.)by FERC account and allocation factor that would
be necessary to properly reflect this updated in-service date and updated
capital addition information in the RAM.
(f) Please update this response if any subsequent changes become known to the
Company.
Response to Bayer Data Request 82
(a) Please refer to the Company's response to IPUC Data Request 171,
specifically Attachment IPUC 171.
(b) Please refer to the Company's response to subpart(a) above.
(c) Please refer to the Company's response to subpart(a) above.
(d) The Company has not prepared an adjustment to remove the canceled and
delayed projects identified in the Company's response to IPUC Data Request
171. Please refer to Attachment Bayer 82 which provides the monthly project

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 82
detail, composite depreciation and amortization rates. Please also refer to the
Company's response to Bayer Data Request 8, specifically Confidential
Attachment Bayer 8, which provides the tax calculations for each of the
projects. Together both attachments can be used to calculate an adjustment.
The Company will provide an adjustment to remove projects that are
cancelled or delayed beyond the test period in its rebuttal filing.
(e) Please refer to the Company's response to subpart (d) above.
(f) The Company will supplement this request when additional information
becomes available.
Recordholder: Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 83
Bayer Data Request 83
Major Plant Additions - Contingency Costs. Regarding Ms. Shelley E.
McCoy's major capital additions adjustment shown included in Exhibit 48,
Adjustment 8.5.
(a) Do any of the projects included in Adjustment 8.5 include contingency costs?
(b) If any of the plant additions included in the Company's pro forma plant
additions adjustment include contingency costs, please describe RMP's
practice regarding the inclusion of contingency costs in its pro forma capital
additions.
(c) If any of the plant additions included in the Company's pro forma plant
additions adjustment include contingency costs, please specify which projects
include contingency costs and the amount included for each project, in Excel
format.
(d) If any plant additions include contingency costs, please indicate whether the
Company's current projection of contingency costs to be used for these
projects varies from the amounts included in the Company's filing. If so,
please provide a current estimate of the amount of contingency cost by
project, in Excel format.
(e) If the Company's current projection of contingency costs varies from the
amount included in the Company's direct filing, please provide a work paper
with formulas intact that derives all the adjustments necessary to completely
remove the contingency costs for the identified projects in the RAM by FERC
account and allocation factor.
Response to Bayer Data Request 83
The Company assumes that the "projects included in Adjustment 8.5" is intended
to be a reference the list of projects provided on page 142 in Exhibit No. 48.
Based on the foregoing assumption, the Company responds as follows:
(a) Yes. Rock Creek I and IKL-Fall Creek Hatchery.
(b) Generation construction and operating project cost estimates are developed as
accurately as possible and, when necessary, include a contingency estimate to
reflect identified risks such as:
0 The length of the construction period.

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 83
• The complexity associated with the project.
• Unforeseen and unpredictable conditions, such as weather and soil
conditions, and uncertainties within the defined project scope such as
commodity prices.
Projects less than $5 million do not include forecasted contingency. Projects
between $5 million and $10 million have very little or no contingency.
(c) Rock Creek I assumed $6,900,000 of contingency in capital spend through
December 31, 2024. IKL-Fall Creek Hatchery assumed $2,990,595 of
contingency in capital spend.
(d) Rock Creek I forecast currently shows $1.7 million through 2024. The current
forecast will include anticipated contingency costs of$4.9 million in 2025.
The current forecast for the IKL-Fall Creek Hatchery is $300,000.
(e) The Company has not prepared an adjustment to update contingency fees.
Information for the regulatory adjustment model (RAM) by FERC Account
and allocation factor is provided below:
• Rock Creek I—FERC Account 343, FERC Account 403OP and FERC
Account 108OP. Depreciation rate of 4.188 percent and allocated using
the system generation (SG) allocation factor.
• The IKL-Fall Creek Hatchery—FERC Account 332, FERC Account
403HP and FERC Account 108HP. Depreciation rate of 2.766 percent and
allocated using the system generation production (SG-P) allocation factor.
Recordholder: Mike Saunders/Karl Mortensen/Gary Tawwater/Craig Larsen
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 84
Bayer Data Request 84
Klamath Regulatory Asset. Please refer to RMP's Adjustment 8.9 -Klamath
Regulatory Asset.
(a) Please provide the work paper, preferably in Excel format with formulas
intact, deriving the December 2023 beginning Total Company balance of
$4,830,028.
(b) Please provide the work paper deriving the monthly Total Company
amortization expense amount of$99,589.
(c) Please provide the complete amortization schedule by month over the 5-year
period that begins with the starting Regulatory Asset balance.
(d) Please compare and explain the difference, if any, for the starting Klamath
Regulatory Asset balance in this rate case with the corresponding balance
from RMP's last Idaho rate case, PAC-E-21-07.
Response to Bayer Data Request 84
(a) Please refer to Attachment Bayer 84.
(b) Please refer to the Company's response to subpart(a) above.
(c) Please refer to the Company's response to subpart(a) above.
(d) No regulatory asset existed in the prior general rate case (GRC), Case PAC-E-
21-07 for the Lower Klamath Facility.
Recordholder: Justus Evangelista
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 85
Bayer Data Request 85
Wildfire Litigation Expenses. For both the 2023 historic period and test year,
please identify the amount of RMP's wildfire litigation expenses (net of any
insurance reimbursements) by FERC account and allocation factor included in
RMP's direct filing. Please identify the location within RMP's filing work papers
where these amounts are included or are identified.
Response to Bayer Data Request 85
Please refer to Confidential Attachment Bayer 85.Note: the total and Idaho
allocated amounts represented in the attachment are for the calendar year 2023
base period. The Company has not applied any pro-forma adjustment to these
balances for the Test Period.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Laura Miller
Sponsor: Shelley McCoy

PAC-E-24-04/Rocky Mountain Power
September 17, 2024
Bayer Data Request 86
Bayer Data Request 86
Wildfire Litigation Expenses. Please provide RMP's wildfire litigation expenses
(net of any insurance reimbursements)by FERC account and allocation factor for
the following periods:
(a) The 2023 historic year.
(b) Calendar year 2022.
(c) Calendar year 2021.
Response to Bayer Data Request 86
(a) Please refer to the Company's response to Bayer Data Request 85.
(b) Please refer to Confidential Attachment Bayer 86.
(c) Please refer to Confidential Attachment Bayer 86.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement(NDA) executed in this proceeding.
Recordholder: Laura Miller
Sponsor: Shelley McCoy

Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response,is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the its response to Bayer Set 6 contains Company proprietary information that could
be used to its commercial disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 17th day of September, 2024.
Respectfully submitted,
By v
Joe Dallas
Attorney
Rocky Mountain Power
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